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358 results for “transfer pricing”+ Section 35(1)(ii)clear

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Key Topics

Addition to Income46Section 26030Section 1487Deduction7Section 14A6Section 356Section 260A5Section 1434Section 92C4

THE COMMISSIONER OF INCOME TAX vs. M/S WIPRO LTD

The appeals stand disposed of, accordingly

ITA/211/2009HC Karnataka25 Mar 2015

Bench: N.KUMAR,B.SREENIVASE GOWDA

Section 260

Transfer Pricing Officer for determination of arms’ length price. As per the return filed the tax payable was Rs.48,38,27,302/-. The assessee also claimed TDS of Rs.6,02,14,066/- and advance tax payment of Rs.59,50,80,000/-. The assessee claimed refund of Rs.17,12,21,725/-. The return of income was processed u/s 143(1

M/S WIPRO LIMITED vs. THE DEPUTY COMMISSIONER OF INCOME TAX

The appeals stand disposed of, accordingly

ITA/881/2008HC Karnataka25 Mar 2015

Bench: N.KUMAR,B.SREENIVASE GOWDA

Section 260

Showing 1–20 of 358 · Page 1 of 18

...
Section 374
Disallowance4
Transfer Pricing3

Transfer Pricing Officer for determination of arms’ length price. As per the return filed the tax payable was Rs.48,38,27,302/-. The assessee also claimed TDS of Rs.6,02,14,066/- and advance tax payment of Rs.59,50,80,000/-. The assessee claimed refund of Rs.17,12,21,725/-. The return of income was processed u/s 143(1

THE PRINCIPAL COMMISSIONER vs. M/S OBULAPURAM MINING

ITA/100012/2017HC Karnataka17 Mar 2023

Bench: K.SOMASHEKAR,UMESH M ADIGA

Section 143(3)Section 144CSection 144C(13)Section 260ASection 37(1)Section 92ASection 92C

price has to be computed under section 92C of the Act, in the cases relating to an international transaction. The term international transaction has been defined in section 92B of the Act. Subsection (1) section 92B eads as under" for the purpose of this Act and section 92, 92C, 92D and 92E, International transaction" means a transaction between

DEVAS MULTIMEDIA PRIVATE LIMITED vs. THE PRINCIPAL COMMISSIONER OF INCOME-TAX

WP/11618/2016HC Karnataka27 Sept 2019

Bench: The Hon’Ble Mr.Justice P.B. Bajanthri Writ Petition No.11618 Of 2016 (T-It) Between:

Section 142(4)Section 143(2)Section 143(3)Section 144Section 144CSection 263Section 92C

Transfer Pricing Officer” means a Joint Commissioner or Deputy 23 Commissioner or Assistant Commissioner authorized by the Board to perform all or any of the functions of an Assessing Officer specified in sections 92C and 92D in respect of any person or class of persons. 144C. (1) xxxxx (2) xxxxx (b) file his objections, if any, to such variation with

M/S INDUS TOWERS LTD vs. THE DEPUTY COMMISSIONER OF COMMERCIAL TAXES

In the result, we pass the following order:

WA/3403/2011HC Karnataka07 Sept 2011

Bench: RAVI MALIMATH,N.KUMAR

Section 4

Section 66 thereof created charge of service tax in regard to taxable services. Service Lax’ is defined in clause (34) of Set lion 65 to mean tax chargeable under the provLsioi is of that napler. 7’axable ceri’icc is dejrnea Iunder sub ‘‘larcsc’ Ib) 1 ½usc 4 1 [ 5j 0 n ° mc a an, srvkc provided tu. znrcr cilia

PR COMMISSIONER OF vs. M/S SOFTBRANDS INDIA

ITA/537/2015HC Karnataka25 Jun 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 260

35. The most important provision concerning us in this batch of cases is Section 92-C of the Act which provides for ‘Computation of Arm’s Length Price’ and Date of Judgment 25-06-2018 I.T.A.No.536/2015 C/w I.T.A.No.537/2015 Pr. Commissioner of Income Tax & Anr. Vs. M/s. Softbrands India P. Ltd., 52/80 the said provision stipulates that

PR COMMISSIONER OF vs. M/S SOFTBRANDS INDIA

ITA/536/2015HC Karnataka25 Jun 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 260

35. The most important provision concerning us in this batch of cases is Section 92-C of the Act which provides for ‘Computation of Arm’s Length Price’ and Date of Judgment 25-06-2018 I.T.A.No.536/2015 C/w I.T.A.No.537/2015 Pr. Commissioner of Income Tax & Anr. Vs. M/s. Softbrands India P. Ltd., 52/80 the said provision stipulates that

WIPRO LIMITED vs. THE JOINT COMMISSIONER OF INCOME TAX

WP/20040/2019HC Karnataka25 Aug 2021

Bench: The Hon’Ble Mr. Justice Krishna S.Dixit Writ Petition No.20040/2019 (T-It) Between:

Section 1Section 143(2)Section 143(3)Section 244ASection 254Section 92C

Transfer Pricing Officer during the proceeding for assessment, reassessment made. The period as specified in sub- section (1)(2) & (3) shall be further extended by 12 months. 153(5) To give effect to the order of the higher authorities i.e. CIT (A), ITAT, HC and SC orders To give effect to an order passed by higher authorities other than those

MR. BINEESH KODIYERI vs. DIRECTORATE OF ENFORCEMENT

WP/13261/2020HC Karnataka16 Mar 2021

Bench: The Hon’Ble Mr. Justice Suraj Govindaraj Writ Petition No. 13261 Of 2020 (Gm-Res) Between: Mr. Bineesh Kodiyeri S/O Mr. Kodiyeri Balakrishnan Aged About 37 Years Kootamvilla Lane, Maruthankuzhi Thiruvananthapuram District Kerala State – 695013

Section 19Section 482

price of which exceeds on e crore rupees; or (d) Fraudulently availing of or attempt to avail of drawback or any exemption from duty provided under this Act, if the amount of drawback or exemption from duty exceeds fifty lakh rupees. WP No. 13261 of 2020 65 (7) Save as otherwise provided in sub-section (6), all other offences under

SMT. M R PRABHAVATHY vs. THE DEPUTY COMMISSIONER OF INCOME TAX

WTA/1/2019HC Karnataka04 Mar 2020

Bench: The Hon’Ble Mr. Justice K.Natarajan Election Petition No.1 Of 2019 Connected With Election Petition No.2 Of 2019

Section 81

Section 33A of RP Act and 106 he has committed corrupt practice of bribery as contemplated under Sections 123(1)(A), 123(1)(B), 123(7), 123(7)(b), 123(vii)(d), 123(7)(h) and Section 123(8), 123(3), 3A and 123(6) of R.P. Act ? The petitioner in E.P. No.2/2019 has contended that respondent No.1 committed corrupt

THE MANGALORE ELECTRICITY SUPPLY COMPANY LTD., vs. SRI A CHANDRASEKHAR

WP/15230/2022HC Karnataka17 Oct 2022

Bench: G.NARENDAR,P.N.DESAI

price fixed under any law, etc. 29. Deficiency of service is defined under Section 2(1)(g) of the Consumer Protection Act, 1986 in the following manner: “2. (1)(g) ‘deficiency’ means any fault, imperfection, shortcoming or inadequacy in the quality, nature and manner of performance which is required to be maintained by or under any law for the time

PR.COMMISSIONER OF INCOMETAX-2 vs. M/S.EYGBS (INDIA) PVT LTD

ITA/107/2025HC Karnataka12 Sept 2025

Bench: CHIEF JUSTICE,C M JOSHI

Section 10ASection 14ASection 260Section 260A

ii) "Whether on facts and circumstances of the case, the Tribunal's order can be said as perverse in nature in not appreciating that the assesee failed to substantiate an furnish details as to how the income in form of TP adjustments has arisen out of the eligible units and to be treated as eligible profits"? (iii) "Whether on facts

THE COMMISSIONER OF INCOME TAX vs. M/S WIPRO LTD

In the result, the appeals are partly allowed

ITA/133/2007HC Karnataka23 Aug 2013

Bench: B.MANOHAR,DILIP B.BHOSALE

Section 260

price of transfer for the purpose of computation of deduction u/s.80HH and 80I of the Act? A-10. Whether the Tribunal was correct in holding that excise duty and sales tax should not be included in the total turnover for the purpose of computation of deduction u/s.80HHC of the Act? 6. In all the three appeals, the following question

M/S INDIA MOTOR PARTS & ACCESSORIES LTD vs. THE DEPUTY COMMISSIONER OF

Of the Department's clouded interpretation of the Centum

WP/2925/2016HC Karnataka29 Mar 2016

Bench: ANAND BYRAREDDY

ii. When the transfer of title to the goods happens; c) Issuance of tax-invoice is an indication of transfer of title to the goods; 35 d) When a dealer sells, the other dealer purchases. Every sale must have a corresponding purchase; e) After the tax-invoice is issued, either the tax is paid immediately or becomes payable. This ‘paid

SONAL APPAREL PRIVATE LTD., vs. THE STATE OF KARNATAKA

Of the Department's clouded interpretation of the Centum

WP/22483/2015HC Karnataka29 Mar 2016

Bench: ANAND BYRAREDDY

ii. When the transfer of title to the goods happens; c) Issuance of tax-invoice is an indication of transfer of title to the goods; 35 d) When a dealer sells, the other dealer purchases. Every sale must have a corresponding purchase; e) After the tax-invoice is issued, either the tax is paid immediately or becomes payable. This ‘paid

M/S. HINDUSTAN COCA COLA vs. STATE OF KARNATAKA

Of the Department's clouded interpretation of the Centum

WP/38509/2015HC Karnataka29 Mar 2016

Bench: ANAND BYRAREDDY

ii. When the transfer of title to the goods happens; c) Issuance of tax-invoice is an indication of transfer of title to the goods; 35 d) When a dealer sells, the other dealer purchases. Every sale must have a corresponding purchase; e) After the tax-invoice is issued, either the tax is paid immediately or becomes payable. This ‘paid

KAVERI PLASTO CONTAINERS PVT LTD vs. THE STATE OF KARNATAKA

Of the Department's clouded interpretation of the Centum

WP/11249/2016HC Karnataka29 Mar 2016

Bench: ANAND BYRAREDDY

ii. When the transfer of title to the goods happens; c) Issuance of tax-invoice is an indication of transfer of title to the goods; 35 d) When a dealer sells, the other dealer purchases. Every sale must have a corresponding purchase; e) After the tax-invoice is issued, either the tax is paid immediately or becomes payable. This ‘paid

M/S. HINDUSTAN COCA COLA vs. STATE OF KARNATAKA

Of the Department's clouded interpretation of the Centum

WP/38510/2015HC Karnataka29 Mar 2016

Bench: ANAND BYRAREDDY

ii. When the transfer of title to the goods happens; c) Issuance of tax-invoice is an indication of transfer of title to the goods; 35 d) When a dealer sells, the other dealer purchases. Every sale must have a corresponding purchase; e) After the tax-invoice is issued, either the tax is paid immediately or becomes payable. This ‘paid

INGRAM MICRO INDIA PVT. LTD. vs. THE STATE OF KARNATAKA

Of the Department's clouded interpretation of the Centum

WP/56067/2015HC Karnataka29 Mar 2016

Bench: ANAND BYRAREDDY

ii. When the transfer of title to the goods happens; c) Issuance of tax-invoice is an indication of transfer of title to the goods; 35 d) When a dealer sells, the other dealer purchases. Every sale must have a corresponding purchase; e) After the tax-invoice is issued, either the tax is paid immediately or becomes payable. This ‘paid

DEPA INDIA PRIVATE LTD. vs. THE STATE OF KARNATAKA

Of the Department's clouded interpretation of the Centum

WP/23533/2015HC Karnataka29 Mar 2016

Bench: ANAND BYRAREDDY

ii. When the transfer of title to the goods happens; c) Issuance of tax-invoice is an indication of transfer of title to the goods; 35 d) When a dealer sells, the other dealer purchases. Every sale must have a corresponding purchase; e) After the tax-invoice is issued, either the tax is paid immediately or becomes payable. This ‘paid